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COCA-COLA BOTTLERS PHILIPPINES v. ILOILO COCA-COLA PLANT EMPLOYEES LABOR UNION

FACTS:

This case involves a dispute between Coca-Cola Bottlers Philippines, Inc. (CCBPI) and its employees over the scheduling of work on Saturdays. The Court of Appeals (CA) ruled that under the collective bargaining agreement (CBA), scheduling work on Saturdays was mandatory for CCBPI. The CA also found that scheduling work on Saturdays had become a company practice and removing it constituted a diminution of benefits. CCBPI filed a motion for reconsideration which was denied, prompting them to file a petition for certiorari before the Supreme Court. CCBPI argued that the provision in the CBA regarding work on Saturdays was optional and a legitimate management prerogative. They disputed that scheduling work on Saturdays had become a company practice and argued that it was compensated with premium pay. The respondents, on the other hand, argued that CCBPI failed to comply with the provision in the CBA mandating the scheduling of work on Saturdays and that CCBPI's refusal to do so constituted a diminution of benefits.

ISSUES:

  1. Whether the CBA mandates that CCBPI schedule Saturday work for its employees.

  2. Whether the phrase "option to schedule work" in the CBA includes the option to allow or disallow Saturday work.

  3. Whether the provision in the Collective Bargaining Agreement (CBA) giving company management the right to schedule work on Saturdays based on operational necessity includes the prerogative not to schedule work.

  4. Whether the scheduling of Saturday work has ripened into a company practice and the removal of such practice constitutes a diminution of benefits.

  5. Whether the withdrawal of Saturday work by the employer constitutes diminution of benefits.

  6. Whether the non-payment of the 50% premium pay for unworked Saturdays violates the non-diminution of benefits rule.

  7. Whether the principle of "no work, no pay" applies to employees who are not scheduled to work on Saturdays.

  8. Whether the employees should be paid their whole daily rate plus the corresponding premium pay for unworked Saturdays.

RULING:

  1. The Court agrees with the interpretation of CCBPI that the CBA does not mandate the scheduling of Saturday work for its employees. The provision in Article 10, Section 1 of the CBA clearly states that Saturday work is not part of the normal work week and is considered a premium day. The option to schedule work on Saturdays is based on operational necessity, indicating that it is not mandatory for CCBPI to schedule work on that day.

  2. The phrase "option to schedule work" in the CBA does not include the option to allow or disallow Saturday work. The Court finds that a more logical interpretation is that the option to schedule work on Saturdays refers to the scheduling of working hours on that day, and not whether work should be allowed on Saturdays. The provision in Article 11, Section 2(c) states that CCBPI has the option to schedule work on Saturdays, and there is no ambiguity in the provision. If the parties had intended to include the option to allow or disallow Saturday work, they would have used specific language to convey that intention.

  3. The provision in the CBA giving company management the right to schedule work on Saturdays based on operational necessity includes the prerogative not to schedule work. The CBA provisions clearly state that work on Saturdays is dependent on the exigencies of the business. The phrase "schedule work on Saturdays based on operational necessity" indicates that there are times when work on Saturdays is required and times when it is not necessary. The CBA gives the company management the prerogative to provide its employees with Saturday work depending on the operational needs of the business.

  4. The scheduling of Saturday work has not ripened into a company practice and the removal of such practice does not constitute a diminution of benefits. The additional compensation or premium paid to employees who work on Saturdays indicates that such work is not part of the regular work week. If Saturday work was part of the regular work week, there would be no need for additional compensation. The provision in the CBA for premium pay for Saturday work suggests that it is not a regular requirement but rather an exception. Therefore, the removal of the Saturday work schedule does not constitute a diminution of benefits.

  5. The withdrawal of Saturday work does not constitute diminution of benefits. The benefit involved in this case is the premium pay given for Saturday work, not the grant of Saturday work itself. Thus, the withdrawal of Saturday work does not violate the non-diminution of benefits rule.

  6. The non-payment of the 50% premium pay for unworked Saturdays does not violate the non-diminution of benefits rule. The CBA between the employer and the employee does not grant that the premium pay will be paid regardless of the occurrence of Saturday work. Furthermore, the grant of Saturday work was made subject to a condition of operational necessity, and when the condition does not prevail, the non-diminution rule does not apply.

  7. Yes, the principle of "no work, no pay" applies to employees who are not scheduled to work on Saturdays.

  8. No, the employees should not be paid their whole daily rate plus the corresponding premium pay for unworked Saturdays.

PRINCIPLES:

  • A CBA is the negotiated contract between a legitimate labor organization and the employer concerning wages, hours of work, and all other terms and conditions of employment in a bargaining unit. Compliance with the CBA is mandated by the law.

  • The literal meaning of the stipulations of the CBA controls if they are clear and unambiguous, leaving no doubt upon the intention of the contracting parties.

  • The various stipulations of a contract should be interpreted together, attributing to the doubtful ones that sense which may result from all of them taken jointly.

  • The provision of a contract, such as a Collective Bargaining Agreement, must be interpreted together and in context to determine the true intention of the parties.

  • The well-settled rule is that the various stipulations of a contract must be interpreted together, giving effect to all the provisions, and avoiding an interpretation that would render any part of the contract meaningless or superfluous.

  • Payment for overtime work does not fall within the definition of benefits and is not protected by Article 100 of the Labor Code, which prohibits the elimination or diminution of benefits. Overtime work is compensation for services rendered in addition to regular work hours and is given only when the services are needed after regular working hours.

  • Benefits under Article 100 of the Labor Code refer to monetary benefits or privileges given to the employee with monetary equivalents.

  • The non-diminution of benefits rule applies when the employer unilaterally withdraws a benefit without abolishing the corresponding obligation, provided that the benefit is not made subject to a condition.

  • The principle of "a fair day's work for a fair day's pay" applies to daily-paid employees, and they are entitled to wages and premiums only if they are permitted to suffer work.

  • The age-old rule governing the relation between labor and capital of a "fair day's wage for a fair day's labor" remains the basic factor in determining employees' wages.

  • In cases where the employee's failure to work was neither caused by abandonment nor termination, each party must bear his own loss and the burden of economic loss should not be shifted to the employer.

  • If there is no work performed by the employee, there can be no wage.

  • The principle of "no work, no pay" applies when the employee is willing and able to work and is not illegally prevented from doing so.

  • The Court's primary role as the vanguard of constitutional guaranties charges it with the duty of ensuring full protection to labor, but this should not lead to the oppression or self-destruction of the employer.

  • Social justice aims to humanize laws and equalize social and economic forces by the State, but justice should be dispensed in accordance with established facts and applicable law and doctrine.